SunnyBay Policies
Anti-Money Laundering Policy
Last edit
28/11/2024
SunnyBay is committed to preventing money laundering and terrorist financing in accordance with the UK’s Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017, as amended. This policy outlines our procedures to ensure compliance with these regulations.
2. Customer Due Diligence (CDD)
- Identification: We will verify the identity of clients through reliable, independent source documents, data, or information.
- Risk Assessment: Each client will be assessed for risk factors, including the nature of the transaction and geographic considerations.
- Ongoing Monitoring: We will continuously monitor transactions to ensure they are consistent with our knowledge of the client and their risk profile.
3. Record Keeping
- Documentation: All records of CDD, transactions, and correspondence will be maintained for a minimum of five years.
- Accessibility: Records will be stored securely and made available to regulatory authorities upon request.
4. Reporting Suspicious Activity
- Internal Reporting: Staff must promptly report any suspicious activity to the appointed Money Laundering Reporting Officer (MLRO).
- External Reporting: The MLRO will evaluate reports and, if necessary, submit a Suspicious Activity Report (SAR) to the National Crime Agency (NCA).
5. Training
- Employee Education: All employees will receive regular training on AML regulations, identifying suspicious activities, and reporting procedures.
6. Policy Review
- Regular Updates: This policy will be reviewed annually or as required to reflect changes in legislation or business operations.